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Contributing Employers to Multiemployer Plans Are Not Off the Hook: Tracking the Full-Time Status of Employees
Proskauer's ERISA Practice Center Link to more items from this source
[Guidance Overview]
Nov. 11, 2014

"Contributing employers to multiemployer plans were relieved by the Treasury Department's interim guidance stating that they will not be subject to the employer shared responsibility payments under the [ACA] with respect to employees for whom they contribute to a multiemployer plan that provides minimum value, offers dependent child coverage and is affordable.... That led many employers to believe mistakenly that they do not have to determine the full-time status of these employees ... [C]ontributing employers still need to determine which employees are full time in order to properly comply with IRS reporting requirements."

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